- Miller-El v. Dretke
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Miller-El v. Dretke
Supreme Court of the United StatesArgued December 6, 2004
Decided June 13, 2005Full case name Miller-El v. Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Divisions Citations 545 U.S. 231 (more)
125 S. Ct. 2317; 162 L. Ed. 2d 196; 2005 U.S. LEXIS 4658; 73 U.S.L.W. 4479; 18 Fla. L. Weekly Fed. S 376Holding The prosecution in the capital trial of Miller-El violated the Fourteenth Amendment as interpreted in Batson v. Kentucky when it racially discriminated against black potential jurors, and Miller-El is entitled to habeas corpus relief. Court membership Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen BreyerCase opinions Majority Souter, joined by Stevens, O'Connor, Kennedy, Ginsburg, Breyer Concurrence Breyer Dissent Thomas, joined by Rehnquist, Scalia Miller-El v. Dretke, 545 U.S. 231 (2005), is a decision by the Supreme Court of the United States that clarified the constitutional limitations on the use by prosecutors of peremptory challenges and of the Texas procedure appropriately termed the "jury shuffle."
Contents
Factual background
Thomas Miller-El was charged with capital murder committed in the course of a robbery. After voir dire, Miller-El moved to strike the entire jury because the prosecution had used its peremptory challenges to strike ten of the eleven African-Americans who were eligible to serve on the jury. This motion was denied, and Miller-El was subsequently found guilty and sentenced to death.
Decision
In 1986, the US Supreme Court ruled in Batson v. Kentucky that a prosecutor's use of peremptory challenges may not be used to exclude jurors on the basis of race. Miller-El appealed based on the Batson criteria and asked that his conviction be overturned. In June 2005, the US Supreme Court ruled 6-3 to overturn Miller-El's death sentence, finding his jury selection process had been tainted by racial bias.
The Court had held in Batson that a defendant could rely on "all relevant circumstances" in making out a prima facie case of purposeful discrimination. Miller-El clarified that "all relevant circumstances" included evidence outside "the four corners of the case."[1] Specifically, the Court allowed statistical analysis of the venire,[2] side-by-side comparison of struck and empaneled jurors,[3] disparate questioning,[4] and evidence of historical discrimination.[5]
Impact
The Court extended the holding of Miller-El in Snyder v. Louisiana .
See also
- List of United States Supreme Court cases, volume 545
- List of United States Supreme Court cases
References
External links
Categories:- Batson challenge case law
- United States Supreme Court cases of the Rehnquist Court
- 2005 in United States case law
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